Proposed Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs


The NHC fully supports the Administration’s efforts to increase transparency of hospital charges and to combat the nation’s opioid crisis through increasing access to alternative pain management techniques. However, we are concerned about potential access issues created by the reconstitution of the competitive acquisition program if not implemented in an incremental fashion with appropriate patient protections.
The NHC Supports CMS’ Efforts to Make Hospital Charges More Transparent to Patients and Consumers.
The NHC fully supports efforts to provide greater system-wide transparency of health care costs. If structured in a way that provides meaningful information about the cost of care, patients will be better able to seek care that best meets their needs. Thus, the NHC appreciates CMS’ interest in improving the accessibility and utility of provider “charge” information and agrees with CMS’ concern that:
[F]or providers and suppliers that maintain a list of standard charges, the charge data are not helpful to patients for determining what they are likely to pay for a particular service or facility encounter. In order to promote greater price transparency for patients, we are considering ways to improve the accessibility and usability of current charge information.
The NHC believes that provider reporting of charges, like all transparency initiatives, should further the goal of improving timely access to information that supports informed decisions and facilitates timely access to the most appropriate course of treatment for the individual patient. From the perspective of patients, the most important cost-related information is the impact on their bottom-line – out-of-pocket cost for treatment. We urge CMS to:

require providers to disclose information in machine-readable format;

encourage, incentivize, and/or require MA plans, Medicare supplemental plans, Medicaid MCOs, and ACA plans to maintain an interface for their beneficiaries that provides an estimate of out-of-pocket costs that patients can access and utilize when making health care decisions; and

maintain transparency for patients with respect to out-of-network costs that might be associated with their care. Patients are often unaware that specific services administered by a provider they believe is “in network” are treated as out-of-network costs until they receive a bill they were not expecting.

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